The Issuer has removed from its website reference to the material resource estimate for the Albany graphite deposit (the “Albany Graphite Deposit”) because the technical report entitled “Technical Report on the Preliminary Economic Assessment of the Albany Graphite Project, Northern Ontario, Canada” dated July 9, 2015 contains an economic analysis that is no longer reliable and can no longer be classified as current. Additionally, the Issuer has revised a corporate presentation on its website to: (i) remove statements related to the Albany Graphite Deposit that can no longer be supported; (ii) remove disclosure of potential international partnerships unless and until any such partnerships are publicly announced; and (iii) address certain material factors and assumptions used to develop forward-looking information. The Company has also filed on SEDAR, as a material contract, a reciprocal supply agreement with Ekomed Global Inc., which, as a material contract, was due to be filed no later than the date of filing of the Company’s Annual Information Form.

The Issuer re-filed its management’s discussion and analysis (“MD&A”) for the year ended December 31, 2021, and for the periods ended March 31, 2022, June 30, 2022 and September 30, 2022, to include corrective disclosure providing additional details and clarifications with respect to the Issuer’s business, operations, financial performance, recent events and trends, primary contracts, objectives and milestones as required under Form 51-102F1 Management’s Discussion and Analysis. As a result of the corrective disclosure re-filings the Issuer also re-filed certifications of interim and annual filings for each MD&A in compliance with National Instrument 52-109 Certification of Disclosure in Issuers’ Annual and Interim Filings.

Additionally, on January 16, 2023, the Issuer filed five material change reports relating to the appointment and resignation of certain officers and directors of the Company, which were required to be filed at an earlier date.

The Issuer filed an amended technical report on the Black Diamond property to remove several supplementary and excessive appendices. The technical report was not previously filed on SEDAR.

The Issuer included enhanced disclosure with respect to its staking operations and custody of its assets.

A news release was issued to indicate that the Issuer refiled its MD&A for year ended June 30, 2021 and June 30, 2022 to address the deficiencies identified by Staff in the corporate governance and audit committee disclosures.

The Issuer filed 4 material contracts, which were required to have been filed at an earlier date. The Issuer also included enhanced disclosure with respect to the materiality of 2 contracts.

Disclosure did not comply with NI 43-101 (deficiency 2 d)

Issuer refiled amended MD&A for periods ended September 30, 2022 and December 31, 2021 to correct disclosure that did not comply with Part 2 of NI 43-101 and refiled a technical report to address deficienciesfv.

The website of Purpose Investments Inc. included statements about the incorporation of ESG considerations into the investment process by the funds that it manages. The statements had the effect of suggesting that the issuers incorporate ESG considerations into their investment process. Revisions to the website were made to clarify that the issuers do not incorporate ESG considerations and to provide more clarity on the funds that do.

The Issuer filed a material change report regarding the appointments and resignations of certain directors and officers during the period from May 14, 2021 to November 12, 2022, which were required to be filed at earlier date

Technical report (deficiency 2d): re-estimation of mineral reserve to conform to CIM definitions; certification by independent report authors

The Issuer reclassified cryptocurrency assets from current to non-current on a retrospective basis and provided corrective disclosure of its approach to executive compensation.

Withdrawal of forward-looking financial information (specifically future revenue and EBITDA) that was included in the Issuer’s news release and investor presentation, each dated October 20, 2022 and filed on SEDAR, and the preliminary prospectus dated October 26, 2022.

The Issuer included corrective disclosures in its Management’s Discussion & Analysis for the period ended September 30, 2022 to remedy deficiencies identified in previously filed documents, including silver-equivalency (AgEq) technical disclosure and discussion of i) the impacts of COVID-19 on the Company; (ii) the Company’s plans and expected costs related to its drilling campaigns; (iii) the effects of Argentine hyperinflation on the Company’s operations; (iv) the factors that have caused variations over the most recent quarterly periods; (v) the business purpose of certain related party transactions; and (v) the Company’s short-term and long-term objectives in the sections pertaining to liquidity and capital resources. In the news release, the Issuer also announced a new mineral resource estimate superseding the prior Preliminary Economic Assessment, which contained deficiencies.

The Issuer clarified disclosure related to its corporate presentation and website to include the name of the qualified person, revise disclosure related to a historical estimate, remove a third party research report, and remove a non-compliant fact sheet.

The Issuer filed a registration statement on Form S-1 with the United States Securities and Exchange Commission that included December 31, 2021 annual financial statements prepared in accordance with US GAAP. The Issuer’s subsequent continuous disclosure filings on SEDAR incorporate by reference the US GAAP financial statements included in the registration statement, which had not been filed on SEDAR pursuant to item 11.1 of National Instrument 51-102. The Issuer filed the Registration Statement, inclusive of the US GAAP Annual Statements, on SEDAR.

The Issuer has amended and restated the previously filed audited financial statements for the financial year ended March 31, 2022 in addressing Staff’s comments from a continuous disclosure review. Part 3.2 of Companion Policy 51-102CP Continuous Disclosure Obligations states that when an issuer changes its auditors during the periods presented in the annual financial statements and the new auditor has not audited the comparative period, the auditor’s report would normally refer to the predecessor auditor’s report unless that predecessor auditor’s report on the comparative period is reissued with the financial statements. As the new auditor’s report did not refer to the predecessor auditor’s report, the amended and restated financial statements therefore include the predecessor auditor’s report, covering the financial year ended March 31, 2021.

The issuer filed executive compensation disclosure that was required to be filed at an earlier date.

The Issuer refiled its financial statements and MD&A for the interim period ended June 30, 2022 to correct the Statements of Cash Flows, which (1) erroneously referred to the current and comparative periods disclosed as “December 31, 2022 and 2021” instead of “June 30, 2022 and 2021”; and (2) presented the incorrect financial information for the comparative period. The Q2 2022 MD&A was also revised to correct commentary related to the Statements of Cash Flows, reflecting changes to the financial information for the 2021 comparative period presented in the revised Q2 2022 financial statements, and an erroneous reference to “the three months ended March 31, 2022”, which should refer to the “the six months ended June 30, 2022”

Technical disclosure in news release (August 22, 2022) did not comply with NI 43-101 (deficiency 2d)

The Issuer clarified its disclosure related to the July 25, 2022 news release regarding the Mont Sorcier Iron and Vanadium Project to indicted that the PEA technical report filed on September 8, 2022 was completed by QPs that are all independent of the Issuer and the PEA was completed using only indicated mineral resources.